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GUIDELINES FOR INDUSTRY ON
CHILD ONLINE PROTECTION
ITU & UNICEF
www.itu.int/cop
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Notices and Disclaimer
This document may be updated from time to time. Updates can be found on the
www.itu.int/cop.
Third-party sources are quoted as appropriate. The International Telecommunication Union
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Mention of and references to specific countries or territories, companies, products,
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organization that the authors are affiliated with, in preference to others of a similar nature
that are not mentioned.
This joint publication reflects the work of ITU and UNICEF with respect to an issue of
common concern. The principles and policies of each agency are separately established
and governed by the relevant decisions of its governing body.
© International Telecommunication Union (ITU) and United Nations Children’s Fund
(UNICEF), 2014.
Requests to reproduce extracts of this publication may be submitted to: [email protected] and
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Acknowledgements
This publication was developed through a consultative process led by the International
Telecommunication Union (ITU) and UNICEF and benefited from the expertise of a wide
range of contributors from leading institutions active in the information and communications
technologies (ICT) sector and on child online safety issues.
UNICEF Corporate Social Responsibility Unit: Amaya Gorostiaga, Eija Hietavuo
UNICEF Child Protection Section: Clara Sommarin
The document also benefited from the review of the following UNICEF colleagues:
Christian Salazar, Maniza Zaman, Bo Viktor Nylund, Susan Bissell, Kerry Neal, Joost
Kooijmans and Julia Schulteis.
ITU: Carla Licciardello, Preetam Maloor, Despoina Sareidaki
Editor: Catherine Rutgers
ITU and UNICEF are grateful to Jenny Jones, GSMA and John Carr, Children’s Charities’
Coalition on Internet Safety, for their continuous support and invaluable guidance to the
overall process.
Moreover, we acknowledge the precious work of our COP Partners, especially (listed in
alphabetical order):
Anika Holterhof and Steven Malby, United Nations Office on Drugs and Crime (UNODC)
2
Anjan Bose, ECPAT International
Ellen Blackler, The Walt Disney Company
Francesca Bosco, United Nations Interregional Crime and Justice Research Institute
(UNICRI)
Giacomo Mazzone, European Broadcasters Union (EBU)
Kim Sanchez, Microsoft Corporation
Martin Schmalzried, Confederation of Family Organizations in the European Union
(COFACE)
Myla Pilao, Trend Micro
Paul Cording, Vodafone Group
Robert Shilling and Mick Moran, Interpol
Roberto Masotti, Emanuela Negro, and Lara Campodonico, Telecom Italia
Sandra Marchenko, International Centre for Missing and Exploited Children (ICMEC)
Susie Hargreaves and Fred Langford, Internet Watch Foundation (IWF)
Finally, ITU and UNICEF thank the wide range of stakeholders who contributed to the
development of the content during the open consultation held in December 2013: Apple;
BCS The Chartered Institute for IT; BSR; Centre for Abuse & Trauma Studies at Middlesex
University; DotKids Foundation; Ericsson; European Commission Directorate-General for
Communications Networks, Content and Technology; Facebook; Information Technology
and Digital Media Development Center; INHOPE; Institute for Human Rights and Business;
Internet Watch Foundation; International Centre for Missing & Exploited Children; LEGO;
Millicom; Nokia; PEGI SA; Telecommunications Regulatory Authority Lebanon; Save the
Children; Telenor Pakistan; TeliaSonera; Virtual Media Center of Kids and Teens
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CONTENTS
GLOSSARY ........................................................................................................... X
PART ONE
Introduction, key areas and general guidelines ................................................ X
1.1 Purpose ............................................................................................................ X
1.2 Background ...................................................................................................... X
1.3 Five key areas for protecting and promoting children’s rights .......................... X
1.4 General guidelines for all related industry ........................................................ X
PART TWO
Sector-specific checklists ................................................................................... X
2.1 Mobile operators .............................................................................................. X
2.2 Internet service providers ………...................................................................... X
2.3 Content providers, online retailers and app developers ................................... X
2.4 User-generated content, interactive and social media service providers ......... X
2.5 National and public service broadcasters ………………………......................... X
2.6 Hardware manufacturers, operating system developers and app stores ......... X
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GLOSSARY
Adolescent – UNICEF (and other United Nations agencies) define adolescents as people
aged 10–19. It is important to note that ‘adolescents’ is not a binding term under
international law, and those below the age of 18 are considered to be children, whereas
those 18–19 years old are considered adults, unless majority is attained earlier under
national law.
Child – In accordance with article 1 of the Convention on the Rights of the Child, a child is
anyone under 18 years old, unless majority is attained earlier under national law.
Child rights impacts – Companies can impact the rights of children, either positively or
negatively, through the ways in which they operate their facilities; develop, deliver and
market products; provide services; apply leverage through business relationships with key
stakeholders and partners; and exert influence on economic and social development.
Under the United Nations Guiding Principles on Business and Human Rights, companies
have a responsibility to identify, prevent, mitigate and, where appropriate, remediate their
potential or actual negative impacts on human rights.
Recognizing the need for explicit guidance about what it means for business to respect and
support children’s rights, the United Nations Global Compact, Save the Children and
UNICEF – together with companies and other stakeholders – released the Children’s
Rights and Business Principles in March 2012. The Principles call on companies to respect
children’s rights, avoid any infringement on the rights of children, and address any adverse
child rights impact with which the business is involved. The Principles also encourage
companies to support children’s rights by taking voluntary actions that seek to advance
children’s rights through core business operations, products and services, strategic social
investments, advocacy, public policy engagement, and working in partnership and other
collective action. To access the full set of Children’s Rights and Business Principles, see
www.unicef.org/csr/12.htm.
Child sexual abuse material – Child sexual abuse material refers to any material that
visually depicts a child in real or simulated explicit sexual activities or any representation of
the sexual parts of a child for primarily sexual purposes, including photography, video,
drawings, cartoons, text and live streaming.1 Although the term ‘child pornography’ is used
commonly in legislation and international conventions, this term is not used in the
Guidelines for Industry on Child Online Protection because ‘pornography’ is frequently
understood to be associated with depictions of sexual activity between consenting adults.
For this reason, use of the term ‘child pornography’ can mischaracterize sexual
representations where children are involved, since it does not highlight the
abusive/exploitative aspects of this phenomenon or reflect the wide spectrum of child
sexual abuse materials, and its use can therefore cause misunderstanding.
Cyberbullying –International law does not define cyberbullying. For the purpose of this
document is it defined as wilful and repeated harm inflicted through the use of computers,
cell phones, and other electronic devices. It may involve direct (such as chat or text
messaging), semipublic (such as posting a harassing message on an e-mail list) or public
communications (such as creating a website devoted to making fun of the victim).2
1
The Optional Protocol to the Convention on the Rights of the Child on the Sale of Children, Child Prostitution
and Child Pornography and the Council of Europe Convention on the Protection of Children against Sexual
Exploitation and Sexual Abuse.
2
Schrock, A., and D. Boyd, ‘Online Threats to Youth: Solicitation, Harassment, and Problematic Content’,
Berkman Center for Internet & Society, Cambridge, p. 21,
http://cyber.law.harvard.edu/sites/cyber.law.harvard.edu/files/RAB_Lit_Review_121808_0.pdf.
5
Grooming – A process intended to lure children into sexual behaviour or conversations
with or without their knowledge, or a process that involves communication and socialization
between the offender and the child in order to make him or her more vulnerable to sexual
abuse. The term ‘grooming’ has not been defined in international law; some jurisdictions,
including Canada, use the term ‘luring’.3
Internet and associated technologies – It is now possible to connect to the Internet
using a variety of different devices, e.g., smartphones, tablets, games consoles, TVs and
laptops as well as more traditional computers. Thus, except where the context suggests
otherwise, any reference to the Internet should be understood to encompass all of these
different methods. To encompass the Internet’s rich and complex tapestry, ‘Internet and
associated technologies’, ‘ICT and online industries’ and ‘Internet-based services’ are used
interchangeably.
Notice and takedown – Operators and service providers are sometimes notified of
suspect content online by customers, members of the public, law enforcement or hotline
organizations. Notice and takedown procedures refer to a company’s processes for the
swift removal (‘takedown’) of illegal content (illegal content being defined according to the
jurisdiction) as soon as they have been made aware (‘notice’) of its presence on their
services.
Parental control tools – Software that allows users, typically a parent, to control some or
all functions of a computer or other device that can connect to the Internet. Typically, such
programmes can limit access to particular types or classes of websites or online services.
Some also provide scope for time management, i.e., the device can be set to have access
to the Internet only between certain hours. More advanced versions can record all texts
sent or received from a device. The programmes normally will be password protected.
URL – The abbreviation stands for ‘uniform resource locator’, the address of an Internet
page.
Wi-Fi – Wi-Fi (Wireless Fidelity) is the group of technical standards that enable data
transmission over wireless networks.
Broadcasting Services – Please refer to the online glossary on www.itu.int/cop .
UNICEF, ‘Child Safety Online: Global Challenges and Strategies’, Innocenti Research Centre, Florence, p.
30, http://www.unicef.org/pacificislands/ict_eng.pdf.
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FOREWORD
The explosion of information and communication technology has created unprecedented
opportunities for children and young people to communicate, connect, share, learn, access
information and express their opinions on matters that affect their lives and their
communities. But wider and more easily available access to the Internet and mobile
technology also poses significant challenges to children’s safety – both online and offline.
To reduce the risks of the digital revolution while enabling more children and young people
to reap its benefits, governments, civil society, local communities, international
organizations and the private sector must come together in common purpose.
The technology industry has a critical role to play in establishing the foundations for safer
and more secure use of Internet-based services and other technologies – for today’s
children and future generations. Businesses must put protecting children at the heart of
their work, paying special attention to protecting the privacy of young users’ personal data,
preserving their right to freedom of expression, and putting systems in place to address
violations of children’s rights when they occur. Where domestic laws have not yet caught
up with international law, business has an opportunity – and the responsibility – to bring
their business practices in line with those standards.
These new Guidelines for Industry on Child Online Protection provide a framework for the
increasingly broad range of companies that develop, provide or make use of information
and communication technologies in the delivery of their products and services. Such
companies are especially well positioned to drive innovative solutions, creating digital
platforms that can expand educational opportunities and enable children and young people
both to engage in the civic life of their communities to become truly global citizens.
Local and national initiatives are critical, and we look forward to collaborating on
complementary guidelines for governments that address the formulation, implementation,
management and monitoring of Country Action Plans to strengthen child online protection.
The Internet knows no boundaries, and our efforts to protect children must be ambitious
and far-ranging. We are grateful to our partners in the Child Online Protection (COP)
Initiative and other organizations participating in the open consultation process for their
invaluable support in developing these guidelines. We look forward to working with our
partners in every sector to make child online protection a priority. And we hope these new
Child Online Protection Guidelines will help create a safer and more secure world for all.
Dr Hamadoun I. Touré
Secretary-General
ITU
Mr Anthony Lake
Executive Director
UNICEF
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PART ONE: INTRODUCTION, KEY AREAS AND
GENERAL GUIDELINES
1.1 Purpose
The Child Online Protection (COP) Initiative is a multi-stakeholder network launched by the
International Telecommunication Union (ITU) to promote awareness of child safety in the
online world and to develop practical tools to assist governments, industry and educators.4
As part of the initiative, in 2009, ITU published a set of COP Guidelines for four groups:
children; parents, guardians and educators; industry; and policymakers. The Guidelines for
Industry on Child Online Protection are aimed at establishing the foundation for safer and
more secure use of Internet-based services and associated technologies for today’s
children and future generations. In response to substantial advances in technology and
convergence, ITU, UNICEF and the COP partners have developed and updated the
Guidelines for the broad range of companies that develop, provide or make use of
telecommunications or related activities in the delivery of their products and services.
The new Guidelines for Industry on Child Online Protection are the result of consultations
with members of the COP Initiative, as well as a wider open consultation that invited
members of civil society, business, academia, governments, media, international
organizations and young people to provide feedback on the Guidelines.
The Guidelines apply to the safety of children when using information and communication
technologies (ICTs). They provide advice on how industry can work to help ensure
children’s safety when using the Internet or any of the associated technologies or devices
that can connect to it, including mobile phones and game consoles. The purpose of this
document is to:
• Establish a common reference point and guidance to the ICT and online industries and
relevant stakeholders.
• Provide guidance to companies on identifying, preventing and mitigating any adverse
impacts of their products and services on children’s rights.
• Provide guidance to companies on identifying ways in which they can promote
children’s rights and responsible digital citizenship among children.
• Suggest common principles to form the basis of national or regional commitments
across all related industries, while recognizing that different types of businesses will
use diverse implementation models.
Part 1 offers general guidelines for industry on protecting children’s safety when using
information and communication technologies, along with recommendations for promoting
positive ICT use, including responsible digital citizenship among children.
Part 2 offers sector-specific checklists that recommend actions to respect and support
children’s rights for the following sectors:
• Mobile operators
• Internet service providers
• Content providers, online retailers and applications (app) developers
4
For more information, see, ITU ‘Child Online Protection’, www.itu.int/cop.
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• User-generated content, interactive and social media service providers
• National and public service broadcasters
• Hardware manufacturers, operating system developers and app stores.
These Guidelines will be updated periodically to reflect new developments and policies as
the technology landscape continues to change.
1.2 Background
During the past 25 years, new information and communication technologies have profoundly
changed the ways in which children interact with and participate in the world around them.
The proliferation of Internet access points, mobile technology and the growing array of
Internet-enabled devices – combined with the immense resources to be found in cyberspace
– provide unprecedented opportunities to learn, share and communicate.
The benefits of ICT usage include broader access to information about social services,
educational resources and health information. As children and families use the Internet and
mobile phones to seek information and assistance, and to report incidents of abuse, these
technologies can help protect children from violence and exploitation. Information and
communication technologies are also used to gather and transmit data by child protection
service providers, facilitating, for example, birth registration, case management, family
tracing, data collection and mapping of violence. Moreover, the Internet has increased
access to information in all corners of the globe, offering children and young people the
ability to research almost any subject of interest, access worldwide media, pursue vocational
prospects and harness ideas for the future.
ICT usage empowers children to assert their rights and express their opinions, and it
provides multiple ways to connect and communicate with their families and friends. In
addition, information and communication technologies serve as a major mode of cultural
exchange and a source of entertainment.
Despite the profound benefits of the Internet, children can also face a number of risks
when using ICTs. Children can be exposed to inappropriate content for their age or to
inappropriate contact, including from potential perpetrators of sexual abuse. They can
suffer reputational damage associated with publishing sensitive personal information either
online or through ‘sexting’, having failed to fully comprehend the implications for
themselves and others of their long-term ‘digital footprints’.
Children may be unaware of the short- and long-term consequences of engaging in risky or
inappropriate behaviours that create negative repercussions for others and themselves.
They also face risks related to online privacy in terms of data collection and usage and the
collection of location information.
The Convention on the Rights of the Child, which is the most widely ratified international
human rights treaty, sets out the civil, political, economic, social, and cultural rights of
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children.5 It establishes that all children have a right to education; to leisure, play and
culture; to obtain appropriate information; to freedom of thought and expression; to privacy
and to express their views on matters that affect them in accordance with their evolving
capacities. The Convention also protects children from all forms of violence, exploitation
and abuse and discrimination of any kind and ensures that the child’s best interest should
be the primary consideration in any matters affecting them. Parents, caregivers, teachers
and people in the community, including community leaders and a range of civil society
actors, have the responsibility to nurture and support children in their passage to adulthood.
Governments have the ultimate responsibility to ensure that parents, caregivers, teachers,
community leaders and civil society actors may fulfil this role. Private sector actors,
including the ICT industry, also have a key responsibility to fulfil children’s rights.
Building on the United Nations Guiding Principles on Business and Human Rights,6 the
Children’s Rights and Business Principles call on businesses to meet their responsibility to
respect children’s rights by avoiding any adverse impacts linked to their operations,
products or services. The Principles also articulate the difference between respect – the
minimum required of business to avoid causing harm to children – and support, for
example, by taking voluntary actions that seek to advance the realization of children’s
rights.
When it comes to protecting children’s rights online, businesses have to strike a careful
balance between children’s right to protection and their right to access to information and
freedom of expression. Therefore companies must ensure that measures to protect
children online are targeted and are not unduly restrictive, either for the child or other users.
Moreover, there is growing consensus in relation to the importance of industry proactively
promoting digital citizenship among children and developing products and platforms that
facilitate children’s positive use of ICTs.
Traditional distinctions between different parts of the telecommunications and mobile
phone industries, and between Internet companies and broadcasters, are fast breaking
down or becoming irrelevant. Convergence is drawing these previously disparate digital
streams into a single current that is reaching billions of people in all parts of the world.
Cooperation and partnership are the keys to establishing the foundations for safer and
more secure use of the Internet and associated technologies. Government, the private
sector, policymakers, educators, civil society, parents and caregivers each have a vital role
in achieving this goal. Industry can act in five key areas, as described in section 1.3.
1.3 Five key areas for protecting and promoting children’s rights
This section outlines five key areas where companies can take actions to protect children’s
safety when using ICTs and promote their positive use of ICTs.
Integrating child rights considerations into all appropriate corporate policies and
management processes
5
6
United Nations, Convention on the Rights of the Child, New York, 20 November 1989,
www.ohchr.org/EN/ProfessionalInterest/Pages/CRC.aspx. All but three countries – Somalia, South Sudan
and the United States – have ratified the Convention on the Rights of the Child.
For more information and to access the full United Nations Guiding Principles document, see
www.business-humanrights.org/UNGuidingPrinciplesPortal/Home.
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Integrating child rights considerations requires that companies take adequate measures to
identify, prevent, mitigate and, where appropriate, remediate potential and actual adverse
impacts on children’s rights. The United Nations Guiding Principles on Business and
Human Rights call on all businesses to put in place appropriate policies and processes to
meet their responsibility to respect human rights.
Businesses should pay special attention to children and youth as a vulnerable group in
regards to data protection and freedom of expression. The United Nations General
Assembly Resolution, “The right to privacy in the digital age” reaffirms the right to privacy
and freedom of expression without being subjected to unlawful interference.78 Additionally,
the Human Rights Council Resolution on “The promotion, protection and enjoyment of
human rights on the Internet”, recognizes the global and open nature of the Internet as a
driving force in accelerating progress towards development and affirms the same rights
people have offline must also be protected online.9 In States which lack adequate legal
frameworks for the protection of children’s rights to privacy and freedom of expression,
companies should follow enhanced due diligence to ensure policies and practices are in
line with international law. As youth civic engagement continues to increase through online
communications, companies have a responsibility to respect children’s rights, even where
domestic laws have not yet caught up with international standards.
Companies can also carry out due diligence as an essential part of their responsibility to
respect children’s rights by including such considerations into human rights, social or
product-level impact assessments, then integrating and acting upon the findings, tracking
responses and communicating how impacts are addressed. Where businesses have
identified that they have caused or contributed to an adverse impact, they have a
responsibility to provide for and cooperate in remediation through internal processes and
by working with appropriate external agencies. Having systems in place to address impacts
as and when they occur allows for an effective, immediate, and restorative response.
Additionally, companies should have in place an operational-level grievance mechanism to
provide a format for affected individuals to raise concerns of potential violations.
Operational level mechanisms should be accessible to girls and boys, their families and
those who represent their interests. Principle 31 of the Guiding Principles on Business and
Human Rights clarifies that such mechanisms should be legitimate, accessible, predictable,
equitable, transparent, rights-compatible, a source of continuous learning, and based on
engagement and dialogue. Together with internal processes to address negative impacts,
grievance mechanisms should ensure companies have frameworks in place to ensure
children have suitable recourse when their rights have been threatened.
When companies take a compliance-based approach towards ICT safety that focuses on
meeting national legislation, following international guidance when national legislation is
not present, and the avoidance of adverse impacts on children’s rights, companies
proactively promote children’s development and well-being through voluntary actions that
7
8
9
United Nations General Assembly Resolution, “The right to privacy in the digital age”, A/RES/68/167,
http://www.un.org/en/ga/search/view_doc.asp?symbol=A/RES/68/167
United Nations Human Rights Council “Report of the Special Rapporteur on the promotion and protection of
the right to freedom of opinion and expression, Frank La Rue”,
http://www2.ohchr.org/english/bodies/hrcouncil/docs/17session/A.HRC.17.27_en.pdf
United Nations Human Rights Council Resolution, “The promotion, protection and enjoyment of
human rights on the Internet”, A/HRC/20/L.13,
http://daccess-dds-ny.un.org/doc/UNDOC/LTD/G12/147/10/PDF/G1214710.pdf?OpenElement
11
advance children’s rights to access information, freedom of expression, participation,
education and culture.
Developing standard processes to handle child sexual abuse material
The Optional Protocol to the Convention on the Rights of the Child on the sale of
children, child prostitution and child pornography defines ‘child pornography’ as any
representation, by whatever means, of a child engaged in real or simulated explicit sexual
activities or any representation of the sexual parts of a child for primarily sexual purposes.10
Of all child sexual abuse material analysed by the Internet Watch Foundation in 2013, 81
per cent of child victims appear to be 10 years of age or younger, and 51 per cent of the
images depicted sexual activity between adults and children, including rape and torture.11
These disturbing facts underscore the importance of collaborative action among industry,
government, law enforcement and civil society to combat child sexual abuse material.
While many governments are tackling the dissemination and distribution of child sexual
abuse material by enacting legislation, pursuing and prosecuting abusers, raising
awareness, and supporting children to recover from abuse or exploitation, many countries
do not yet have adequate systems in place. Mechanisms are required in each country to
enable the general public to report abusive and exploitative content of this nature. Industry,
law enforcement, governments and civil society must work closely with each other to
ensure that adequate legal frameworks in accordance with international standards are in
place. Such frameworks should criminalize all forms of child sexual abuse and exploitation,
including through child abuse materials, and protect the children who are victims of such
abuse or exploitation, and ensure that reporting, investigative and content removal
processes work as efficiently as possible.12
Responsible companies are taking a number of steps to help prevent their networks and
services from being misused to disseminate child sexual abuse material. These include
placing language in terms and conditions or codes of conduct that explicitly forbid such
content;13 developing robust notice and takedown processes; and working with and
supporting national hotlines.
Additionally, some companies deploy technical measures to prevent the misuse of their
services or networks for sharing known child sexual abuse material. For example, some
Internet service providers are also blocking access to URLs confirmed by an appropriate
authority as containing child sexual abuse material if the website is hosted in a country
where processes are not in place to ensure it will be rapidly deleted. Others are deploying
hashing technologies to automatically locate images of child sexual abuse that are already
known to law enforcement/hotlines.
Creating a safer and age-appropriate online environment
10
11
12
13
United Nations, Optional Protocol to the Convention on the Rights of the Child on the sale of children, child
prostitution and child pornography, article 2, New York, 25 May 2000,
www.ohchr.org/EN/ProfessionalInterest/Pages/OPSCCRC.aspx.
Internet Watch Foundation, ‘Annual & Charity Report 2013’, LINX, UK,
https://www.iwf.org.uk/accountability/annual-reports/2013-annual-report
Industry should provide links to national hotlines from their websites. In places where a hotline is not yet
established, industry could refer reporters to the International Association of Hotlines at www.inhope.org
where any of the international hotlines can be selected to make a report.
It should be noted that inappropriate user conduct is not limited to child sexual abuse material and that any
type of inappropriate behaviour or content should be handled accordingly by the company.
12
Very few things in life can be considered absolutely safe and risk free all of the time. Even
in cities where the movement of traffic is highly regulated and closely controlled, accidents
still happen. By the same token, cyberspace is not without risks, especially for children.
Children can be thought of as receivers, participants and actors in their online environment.
The risks that they face can be categorized into three areas:14
• Inappropriate content – Children may stumble upon questionable content while
searching for something else by clicking a presumably innocuous link in an instant
message, on a blog or when sharing files. Children may also seek out and share
questionable material. What is considered harmful content varies from country to
country, yet examples include content that promotes substance abuse, racial hatred,
risk-taking behaviour or suicide, anorexia or violence.
• Inappropriate conduct – Children and adults may use the Internet to harass or even
exploit other people. Children may sometimes broadcast hurtful comments or
embarrassing images or may steal content or infringe on copyrights.
• Inappropriate contact – Both adults and young people can use the Internet to seek out
children or other young people who are vulnerable. Frequently, their goal is to
convince the target that they have developed a meaningful relationship, but the
underlying purpose is manipulative. They may seek to persuade the child to perform
sexual or other abusive acts online, using a webcam or other recording device, or they
will try to arrange an in-person meeting and physical contact. This process is often
referred to as ‘grooming’.
Online safety is a community challenge and an opportunity for industry, government and
civil society to work together to establish safety principles and practices. Industry can offer
an array of technical approaches, tools and services for parents and children. These can
include offering tools to develop new age-verification systems or to place restrictions on
children’s consumption of content and services, or to restrict the people with whom children
might have contact or the times at which they may go online.
Some programmes allow parents to monitor the texts and other communications that their
children send and receive. If programmes of this type are to be used, it is important this is
discussed openly with the child, otherwise such conduct can be perceived as ‘spying’ and
may undermine trust within the family.
Acceptable use policies are one way that companies can establish what type of behaviour
by both adults and children is encouraged, what types of activities are not acceptable, and
the consequences of any breaches to these policies. Reporting mechanisms should be
made available to users who have concerns about content and behaviour. Furthermore,
reporting needs to be followed up appropriately, with timely provision of information about
the status of the report. Although companies can vary their implementation of follow-up
mechanisms on a case-by-case basis, it is essential to set a clear time frame for responses,
communicate the decision made regarding the report, and offer a method for following up if
the user is not satisfied with the response.
Online content and service providers can also describe the nature of content or services
14
Livingstone, S., and L. Haddon, ‘EU Kids Online: Final report’, EU Kids Online, London School of
Economics and Political Science, London (EC Safer Internet Plus Programme Deliverable D6.5), June
2009, p. 10.
13
they are providing and the intended target age range. These descriptions should be
aligned with pre-existing national and international standards, relevant regulations, and
advice on marketing and advertising to children made available by the appropriate
classification bodies. This process becomes more difficult, however, with the growing
range of interactive services that enable publication of user-generated content, for example,
via message boards, chat rooms and social networking services. When companies
specifically target children, and when services are overwhelmingly aimed at younger
audiences, the expectations in terms of content and security will be much higher.
Companies are also encouraged to adopt the highest privacy standards when it comes to
collecting, processing and storing data from or about children as children may lack the
maturity to appreciate the wider social and personal consequences of revealing or
agreeing to share their personal information online, or to the use of their personal
information for commercial purposes. Services directed at or likely to attract a main
audience of children must consider the risks posed to them by access to, or collection and
use of, personal information (including location information), and ensure those risks are
properly addressed. In particular, companies should ensure the language and style of any
materials or communications used to promote services, provide access to services, or by
which personal information is accessed, collected and used, aid understanding and assist
users in managing their privacy in clear and simple ways.
Educating children, parents and teachers about children’s safety and their
responsible use of ICTs
Technical measures can be an important part of ensuring that children are protected from
the potential risks they face online, but these are only one element of the equation.
Parental control tools and awareness raising and education are also key components that
will help empower and inform children of various age groups, as well as parents,
caregivers and educators. Although companies have an important role in ensuring that
children use ICTs in the most responsible and safest possible way, this responsibility is
shared with parents, schools, and children.
Many companies are investing in educational programmes designed to enable users to
make informed decisions about content and services. Companies are assisting parents,
caregivers and teachers in guiding children and adolescents towards safer, more
responsible and appropriate online and mobile phone experiences. This includes
signposting age-sensitive content and ensuring that information on items such as content
prices, subscription terms and how to cancel subscriptions, is clearly communicated.
It is also important to provide information directly to children on safer ICT use and positive
and responsible behaviour. Beyond raising awareness about safety, companies can
facilitate positive experiences by developing content for children about being respectful,
kind and open-minded when using ICTs and keeping an eye out for friends. They can
provide information about actions to take if they have negative experiences such as online
bullying or grooming, making it easier to report such incidents and providing a function to
opt out of receiving anonymous messages.
Parents sometimes have less understanding and knowledge of the Internet and mobile
devices than children. Moreover, the convergence of mobile devices and Internet services
makes parental oversight more difficult. Industry can work in collaboration with government
14
and educators to strengthen parents’ abilities to support their children to behave as
responsible digital citizens. The aim is not to transfer responsibility for children’s ICT use to
parents alone, but to recognize that parents are in a better position to decide what is
appropriate for their children and should be aware of all risks in order to better protect their
children and empower them to take action.
Information can be transmitted online and offline through multiple media channels, taking
into consideration that some parents do not use Internet services. Collaborating with
school districts to provide curricula on online safety and responsible ICT use for children
and educational materials for parents is important. Examples include explaining the types
of services and options available for monitoring activities, actions to take if a child is
experiencing online bullying or grooming, how to avoid spam and manage privacy settings,
and how to talk with boys and girls of different age groups about sensitive issues.
Communication is a two-way process, and many companies provide options for customers
to contact them to report issues or discuss concerns.
As content and services grow ever richer, all users will continue to benefit from advice and
reminders about the nature of a particular service and how to enjoy it safely.
Promoting digital technology as a mode for increasing civic engagement
The Convention on the Rights of the Child, in article 13, states that “the child shall have the
right to freedom of expression; this right shall include freedom to seek, receive and impart
information and ideas of all kinds, regardless of frontiers, either orally, in writing or in print,
in the form of art, or through any other media of the child’s choice.” Companies can fulfil
their respect for children’s civil and political rights by ensuring that technology, legislation
and policies developed to protect children from online harm do not have the unintended
consequences of supressing their right to participation and expression or preventing them
from accessing information that is important to their well-being.
At the same time, businesses can also support children’s rights by offering mechanisms
and tools to facilitate youth participation. They can emphasize the Internet’s capacity to
facilitate positive engagement in broader civic life, drive social progress, and influence the
sustainability and resiliency of communities, for example, by participating in social and
environmental campaigns and holding those in charge accountable. With the right tools
and information, children and young people are better placed to access opportunities for
health care, education and employment, and to voice their opinions and needs in schools,
communities and countries. They can access information about their rights and make
demands for information, whether in terms of the right to information on matters that affect
them, such as their sexual health, or political and government accountability.
Companies can also invest in the creation of online experiences that are appropriate for
children and families. They can support the development of technology and content that
encourage and enable children and young people to learn, innovate and create solutions.
Companies can, in addition, proactively support children’s rights by working to close the
digital divide. Children’s participation requires digital literacy – the ability to understand and
participate in the digital world. Without this ability, citizens will not be able to participate in
many of the social functions that have become ‘digitized’, including but not limited to filing
taxes, supporting political candidates, signing online petitions, registering a birth, or simply
15
accessing commercial, health, educational or cultural information. The gap between
citizens who are able to access these forums and those who cannot due to a lack of
Internet access or digital literacy will continue to widen – placing the latter groups at a
significant disadvantage. Companies can support multimedia initiatives to provide the
digital skills that children need to be confident, connected and actively involved citizens.
1.4 General guidelines for all related industry
Table 1 outlines broad guidelines for industry in identifying, preventing and mitigating any
adverse impacts of products and services on children rights – and for promoting children’s
positive use of information and communication technologies. Note that not all the steps
listed in table 1 will be appropriate across all companies; the sector-specific checklists in
tables 2–7 will highlight those steps that are most relevant for individual business sectors.
Table 1. General guidelines for ALL RELATED INDUSTRY
Industry can identify, prevent and mitigate the adverse impacts of ICTs on
children’s rights, and identify opportunities to support the advancement of
children’s rights by taking the following actions:
Ensure that a specific individual and/or a team is designated with responsibility
for this process and has access to the necessary internal and external
stakeholders. Provide this person/team with the authority to take the lead in
raising the profile of child online protection across the company.
Integrating child
rights
considerations
into all
appropriate
corporate
policies and
management
processes
Develop a child protection/safeguarding policy and/or integrate specific
children’s rights risks and opportunities into companywide policy commitments
(e.g., human rights, privacy, marketing and relevant codes of conduct).
Integrate due diligence on child online protection issues into existing human
rights or risk assessment frameworks (e.g., at the corporate level, product or
technology level, and/or at the country level) to determine whether the
business may be causing or contributing to adverse impacts through its own
activities, or whether adverse impacts may be directly linked to its operations,
products or services or business relationships.
Identify child rights impacts on different age groups as a result of company
operations and the design, development and introduction of products and
services – as well as opportunities to support children’s rights.
Draw upon internal and external expertise and consult with key stakeholders,
including children, on child online safety mechanisms to obtain ongoing
feedback and guidance on company approaches.
In States which lack adequate legal frameworks for the protection of children’s
rights to privacy and freedom of expression, companies should ensure policies
and practices are in line with international standards. (UN General Assembly
Resolution, “The right to privacy in the digital age”, A/RES/68/167)
Ensure access to remedy by putting in place operational-level grievance and
reporting mechanisms for any child rights violations (e.g., child sexual abuse
material, inappropriate content or contact, breaches of privacy).
Developing
standard
In collaboration with government, law enforcement, civil society and hotline
organizations, industry has a key role to play in combating child sexual
abuse material by taking the following actions:
16
processes to
handle child
sexual abuse
material
Put in place internal procedures to ensure compliance under local and
international laws on combating child sexual abuse material. When national
regulations do not provide sufficient protection, companies should seek to go
above and beyond the national regulations and use their leverage to lobby for
legislative changes to enable industry to take steps to combat child sexual
abuse material.
Use customer terms and conditions and/or acceptable use policies to explicitly
state the company’s position on the misuse of its services to store or share
child sexual abuse material and the consequences of any abuse.
Develop notice and take down (NTD) and reporting processes that allow users
to report child sexual abuse material or inappropriate contact and the specific
profile/location where it was discovered. Ensure a process is in place to act on
those reports, and agree on procedures to capture evidence and remove
abusive content.
If a company is operating in markets with less developed regulatory and law
enforcement oversight of these issues, it can refer reporters to the International
Association of Hotlines at www.inhope.org/gns/home.aspx, where any of the
international hotlines can be selected to make a report.
Industry can help create a safer, more enjoyable digital environment for
children of diverse ages by taking the following actions:
Employ appropriate technical measures – such as parental control tools, agedifferentiated experiences with password-protected content, block/allow lists,
purchase/time controls, opt-out functions, filtering and moderating15 – to
prevent underage access and exposure to inappropriate content or services.
Where possible, consider the use of age verification to limit access to content
or material that, either by law or policy, is intended only for persons above a
certain age. At the same time, companies should recognize the potential for
misuse of such technologies in ways that could restrict children’s right to
freedom of expression and access to information.
Creating a safer
and ageappropriate
online
environment
In addition to the terms and conditions, communicate clear rules in accessible
and easily understood language that emphasizes what behaviour is and is not
acceptable on the service, and is particularly geared for young users and for
their parents and caregivers. Be sure to state the consequences of breaking
any of these rules.
Ensure that content and services that are not age-appropriate for all users are:
- classified in line with national expectations;
- consistent with existing standards in equivalent media;
- marked with prominent display options to control access;
- offered together with age verification, where possible.
Adapt and implement heightened default privacy settings for collection,
processing, storage, sale and publishing of personal data, including locationrelated information and browsing habits, gathered from people under 18.
Default privacy settings and information about the importance of privacy should
be appropriate to the age of the users and the nature of the service.
Offer clear reporting tools and develop a process to act on reports of
inappropriate content, contact and misuse, and provide detailed feedback to
service users on the reporting process.
15
Within online spaces, degrees of moderation include: pre-moderated (nothing is published before approval of
the webmaster); real time (comments are published, but the moderator can remove them as soon as
anything unacceptable is noticed); post-moderated (a moderator intervenes at a later stage to remove
content).
17
Align business practices with relevant regulations and advice on marketing and
advertising to children. Monitor where, when and how children might encounter
potentially harmful advertising messages intended for another market segment.
Industry can complement technical measures with educational and
empowerment activities by taking the following actions:
Clearly describe available content and corresponding parental controls or
family safety settings. Make language and terminology accessible, visible, clear
and relevant for all users – including children, parents and caregivers –
especially in relation to terms and conditions, costs involved in using content or
services, privacy policies, safety information and reporting mechanisms.
Educating
children, parents,
and teachers
about children’s
safety and their
responsible use
of ICTs
Educate customers on how to manage concerns relating to Internet usage –
including spam, data theft and inappropriate contact such as bullying and
grooming – and describe what actions customers can take and how they can
raise concerns on inappropriate use.
Set up mechanisms and educate parents to become involved in their children’s
ICT activities, particularly those of younger children, for example, providing
parents with the ability to review children’s privacy settings and with information
on age verification.
Collaborate with government and educators to build parents’ abilities to support
and speak with their children about being responsible digital citizens and ICT
users.
Based on the local context, provide materials for use in schools and homes to
educate and enhance children’s use of information and communication
technologies and help children develop critical thinking that enables them to
behave safely and responsibly when using ICT services.
Industry can encourage and empower children by supporting their right to
participation through the following actions:
Establish written procedures that ensure consistent implementation of policies
and processes that protect freedom of expression for all users, including
children, as well as documentation of compliance with these policies.
Promoting digital
technology as a
mode to further
civic engagement
Avoid over-blocking of legitimate, developmentally appropriate content. In order
to ensure that filtering requests and tools are not misused in ways that restrict
children’s access to information, be transparent about blocked content and
establish a process for users to report inadvertent blocking; this process should
be available to all consumers, including webmasters. Any reporting process
should provide clear, responsible and adjudicated terms of service.
Develop online platforms that promote children’s right to express themselves;
facilitate participation in public life; and encourage collaboration,
entrepreneurship and civic participation.
Develop educational content for children to be distributed through media and
schools that encourages learning, creative thinking and problem solving.
Promote digital literacy, capacity building and ICT skills to equip children,
particularly children in rural and underserved areas, to utilize ICT resources
and fully participate safely in the digital world.
Collaborate with local civil society and government on national/local priorities
for expanding universal and equitable access to information and
communication technologies, platforms and devices – and the underlying
infrastructure to support them.
18
PART TWO: SECTOR-SPECIFIC CHECKLISTS
Part 2 offers recommendations for how businesses in specific sectors can respect and
support children’s rights online. It outlines how the common principles and approaches
presented in table 1 can be implemented more specifically as they affect businesses in
different sectors. The checklists are organized by the same key areas and, in some cases,
will refer back to the general guidelines in table 1.
The following sector checklists are not exhaustive, but are intended as a starting point for
companies to respect and support children’s rights in the online sphere. Each of the sector
checklists has been developed in collaboration with key contributors and, as a result, there
are minor variations in the tables.
2.1 Mobile operators
Mobile operators enable access to the Internet as well as offer a range of mobile-specific
data services. Many operators have already signed up to COP codes of practice, and offer
a range of tools and information resources to support their commitments.
Table 2 provides guidance for mobile operators on policies and actions they can take to
enhance child online protection and participation.
Table 2. COP checklist for MOBILE OPERATORS
Integrating child
rights
considerations
into all
appropriate
corporate
policies and
management
processes
Mobile operators can identify, prevent and mitigate the adverse impacts of
ICTs on children’s rights, and identify opportunities to support the
advancement of children’s rights.
Developing
standard
In collaboration with government, law enforcement, civil society and hotline
organizations, mobile operators can play a key role in combating child
sexual abuse material by taking the following actions:
Refer to the general guidelines in table 1.
19
processes to
handle child
sexual abuse
material
Collaborate with government, law enforcement, civil society and hotline
organizations to effectively handle child sexual abuse material and report
cases to the appropriate authorities. If a relationship with law enforcement and
a hotline is not already established, engage with them to develop processes
together. Mobile companies may also provide ICT training for law enforcement.
If a company is operating in markets with less developed legal and law
enforcement oversight of this issue, it can refer reporters to the International
Association of Internet Hotlines at www.inhope.org/gns/report-here.aspx where
any of the international hotlines can be selected to make a report.
Resources:
The GSM Association (GSMA) has developed law enforcement training
materials relating specifically to mobile. To get in contact the GSMA to access
the documents listed, please email [email protected].
Work with internal functions such as customer care, fraud and security to
ensure that the business can submit reports of suspected illegal content
directly to law enforcement and hotlines. Ideally, this should be done in a way
that does not expose front-line staff to the content and re-victimize the affected
child/children. In situations where staff may be exposed to abusive material,
implement a policy or programme to support staff resiliency, safety and wellbeing.
Support law enforcement in the event of criminal investigations through such
activities as capturing evidence. Make sure that terms of service and conditions
state that the company will collaborate fully with law enforcement investigations
in the event that illegal content is discovered or reported.
Use terms of service and conditions to specifically prohibit using mobile
services to store/share or distribute child sexual abuse materials. Make sure
these terms clearly state that child sexual abuse material will not be tolerated.
Promote reporting mechanisms for child sexual abuse material and make sure
that customers know how to make a report if they discover such material. If a
national hotline is available, offer a link to the hotline from the corporate
website and from any relevant content services promoted by the company.
Resource:
Vodafone, ‘Illegal Content’, www.vodafone.com/content/parents/getinvolved/illegal_content.html
If a national hotline is not available, explore opportunities to set one up (see the
GSMA INHOPE Hotlines guide in ‘Resources’ for a range of options, including
working with INHOPE and the INHOPE Foundation or using the Internet Watch
Foundation International back-office solution) – and/or develop internal
processes for customer care staff to submit reports of questionable content to
law enforcement and www.inhope.org.
Resources:
GSMA INHOPE, ‘Hotlines: Responding to reports of illegal online content – A
guide to establishing and managing a hotline organization’. This document
includes information on the IWF Foundation (for countries that need support
building up their own hotline), as well as IWF International’s back office
solution, OCSARP (for countries that want to offer reporting but do not yet
need a full national hotline) http://www.gsma.com/publicpolicy/myouth/mobilescontribution-to-child-protection/mobile-alliance
Have processes in place to immediately remove or block access to child sexual
abuse material – including notice and takedown processes to remove illegal
20
content as soon as it is identified. Ensure that third parties with whom the
company has a contractual relationship have similarly robust notice and
takedown processes in place.
Resources:
GSMA Mobile Alliance Against Child Sexual Abuse Content, ‘Obstructing the
Use of the Mobile Environment by Individuals or Organisations Wishing to
Consume or Profit from Child Sexual Abuse Content’,
www.gsma.com/publicpolicy/myouth/mobiles-contribution-to-childprotection/mobile-alliance
‘Notice and Take Down Process Paper’, www.gsma.com/publicpolicy/wpcontent/uploads/2012/07/Mobilecontributiontonoticeandtakedown.pdf
GSMA Mobile Alliance Against Child Sexual Abuse Content: Preventing mobile
payment services from being misused to monetise child sexual abuse content’,
http://www.gsma.com/publicpolicy/myouth/mobiles-contribution-to-childprotection/mobile-alliance
Mobile operators can help create a safer, more enjoyable digital
environment for children of diverse ages by taking the following actions:
Creating a safer
and ageappropriate
online
environment
Establish a clear set of rules that are prominently placed and echo key points
from the terms of service and acceptable use guidelines. User-friendly
language for these rules should define:
- the nature of the service and what is expected of its users;
- what is and is not acceptable in terms of harmful content, behaviours and
language, as well as prohibiting illegal usage and the consequences
appropriate to the level of any breach – for example, reporting to law
enforcement or suspension of the user’s account.
Make it easy for customers to report concerns about misuse to customer care,
with standard and accessible processes in place to deal with different
concerns, for example, if a customer is receiving unwanted communications
(spam, bullying) or has seen inappropriate content.
Be transparent, giving customers clear information about the nature of the
services that are offered, for example:
- type of content/service and costs;
- minimum age required for access;
- availability of parental controls, including what the controls cover (e.g.,
network) or do not cover (e.g., Wi-Fi) and training for their use;
- what type of user information is collected and how it is used.
Resources:
GSMA, ‘Privacy Design Guidelines for Mobile Application Development’,
www.gsma.com/publicpolicy/privacy-design-guidelines-for-mobile-applicationdevelopment
ICT Coalition, www.ictcoalition.eu
Provide technical controls that are appropriate for the services offered and are
as easy as possible for end users to implement. Such controls might include:
- the ability to block or filter access to the Internet through the company’s
networks, including ‘own brand’ or third-party services that are promoted by
the company;
- age verification if the company’s own content or services include elements
that are only legal or appropriate for adult users (e.g., certain games,
lotteries).
21
Promote national support services that enable children to report and seek
support in the case of abuse or exploitation (see, for example, Child Helpline
International: www.childhelplineinternational.org).
Mobile operators can complement technical measures with educational and
empowerment activities by taking the following actions:
Educating
children, parents
and teachers
about children’s
safety and their
responsible use
of ICTs
Inform customers – including parents, caregivers, children – about the services
offered, for example:
- type of content offered and corresponding parental controls;
- how to report abuse, misuse and inappropriate or illegal content;
- how this report will be handled;
- what services are age restricted;
- safe and responsible behaviour when using ‘own-brand’ interactive services.
Engage with the broader issues around safe and responsible digital citizenship,
e.g., online reputation and digital footprint, harmful content, grooming. Consider
partnering with local experts such as children’s non-governmental
organizations, charities and parenting groups to help shape the company’s
messaging and reach the intended audience.
If the business already works with children or schools – for example, through
corporate social responsibility programmes – investigate whether this
engagement could be extended to include educating children and teachers on
child online protection messages.
Mobile operators can encourage and empower children by supporting their
right to participation.
Promoting digital
technology as a
mode to further
civic engagement
Refer to the general guidelines in table 1.
Resources:
GSMA, ‘mEducation’, www.gsma.com/connectedliving/meducation;
‘Mobile for Development’, www.gsma.com/mobilefordevelopment including
‘mWomen’ http://www.gsma.com/mobilefordevelopment/programmes/mwomen
2.2 Internet service providers
Internet service providers act as both a conduit, providing access to and from the Internet,
and a repository for data through their hosting, caching and storage services. As a result,
they have been in the forefront of accepting responsibility for protecting children online.
Table 3 provides guidance for Internet service providers on policies and actions they can
take to enhance child online protection and participation.
Table 3. COP checklist for INTERNET SERVICE PROVIDERS
Integrating child
rights
considerations
into all
appropriate
corporate policies
and management
processes
Internet service providers can identify, prevent and mitigate the adverse
impacts of ICTs on children’s rights, and identify opportunities to support
the advancement of children’s rights.
Refer to the general guidelines in table 1.
22
In collaboration with government, law enforcement, civil society and
hotline organizations, Internet service providers can play a key role in
combating child sexual abuse material by taking the following actions:
Prohibit uploading, posting, transmitting, sharing or making available content
that violates the rights of any party or infringes any local, state, national or
international law.
Communicate with national law enforcement agencies or the national
hotline(s) to pass on reports of illegal child sexual abuse material as soon as
the provider is aware of it. Make sure that internal procedures are in place to
comply with reporting responsibilities under local and international laws.
Developing
standard
processes to
handle child
sexual abuse
material
If a company is operating in markets with less developed regulatory and law
enforcement oversight of this issue, it can refer reporters to the International
Association of Internet Hotlines at www.inhope.org/gns/home.aspx, where any
of the international hotlines can be selected to make a report.
Have processes in place to immediately remove or block access to child
sexual abuse material – including notice and takedown processes to remove
illegal content as soon as it is identified. Ensure that third parties with whom
the company has a contractual relationship have similarly robust notice and
takedown processes in place.
Link reports of abuse to the processes with a public service agreement on the
response procedure and takedown times.
Actively assess commercial content hosted on the company’s servers,
whether branded or contracted from third-party content providers, on a regular
basis. Consider using such tools as hash scanning of known images, image
recognition software or URL blocking to handle child sexual abuse material.
Set up a reporting mechanism that offers clear information for its usage, for
example, give guidance on the illegal content and conduct to be reported and
clarify what materials cannot be attached with the report in order to avoid
further distribution on the web.
Internet service providers can help create a safer, more enjoyable digital
environment for children of diverse ages by taking the following actions:
Identify customers’ age where appropriate, implementing a suitable solution
according to individual services. This will be particularly important when the
service is subject to legal restrictions based on age.
Creating a safer
and ageappropriate online
environment
Consider presenting the reporting function on all web pages and services.
Seek to standardize the company’s approach to reporting abuse or other
breaches of a website’s or online service’s terms and conditions. When they
move from one site to another, it should not be necessary for children or their
parents to learn a new set of processes to report issues.
Consider providing mechanisms such as parental control software and tools
that enable parents to manage their children’s access to Internet resources,
e.g., white lists, content filters, usage monitoring, contact management,
time/program limits.
Use terms of service/terms and conditions to specifically prohibit unacceptable
behaviour and include a minimum user age.
Where possible, promote national support services that parents and
caregivers may use to report and seek support in the case of abuse or
exploitation.
Avoid harmful or inappropriate advertising content online, and establish
disclosure obligations to customers for services with content that is intended
for an adult audience and could be harmful to children.
23
Ensure that data collection policies comply with relevant laws concerning
children’s privacy, including whether parental consent is required before
commercial enterprises can collect personal information from or about a child.
Internet service providers can complement technical measures with
educational and empowerment activities by taking the following actions:
Within guidelines for children, parents and caregivers, echo key messages
from terms and conditions in user-friendly language. Within the service itself,
at the point of uploading content, include ‘reminders’ about such topics as the
type of content that is considered to be inappropriate.
Educating
children, parents
and teachers
about children’s
safety and their
responsible use of
ICTs
Promoting digital
technology as a
mode to further
civic engagement
Provide parents with the necessary information to understand how their
children are using ICT services, e.g., including how to handle issues related to
harmful content and conduct, and be well-positioned to guide them towards
responsible usage. This can be facilitated by use of tools and through
interactions with school districts to provide online safety curricula for children
and educational materials for parents.
Provide children with information on safer Internet use. Consider setting up
messages on the Internet service provider landing page, e.g.,
- “Never share any contact details, including your physical location and your
phone number, with anyone you don’t know in person.”
- “Never agree to get together with anyone you have met online on your own
without consulting an adult first. Always tell a trusted friend or adult about
your whereabouts.”
- “Do not respond to bullying, obscene or offensive messages. But save the
evidence – do not delete the message.”
- “Tell a trusted adult or a friend if you are uncomfortable or upset about
something or someone.”
- “Never give away your account password or username! Be aware that
other people online may give false information to convince you to share
your private information.”
Internet service providers can encourage and empower children by
supporting their right to participation.
Refer to the general guidelines in table 1.
Resource:
Family Online Safety Institute (FOSI), ‘A Platform for Good’,
www.aplatformforgood.org
24
Internet access in public spaces
It is becoming increasingly common for municipalities, retailers, transportation companies,
hotel chains and other businesses and organizations to provide Internet access via Wi-Fi
hotspots. Such access is typically free or provided at minimal cost, and sometimes with
minimal sign-on formalities, as a public service or by a company to attract customers to its
premises or persuade more people to use its services.
Promoting Wi-Fi is a great way to spread Internet availability in a given area. Care needs to
be taken, however, when such access is being provided in public spaces where children
are likely to be present on a regular basis. Users need to be mindful that Wi-Fi signals
might be available to passers-by and user data compromised. The Wi-Fi provider will
therefore not always be able to support or supervise the use of an Internet connection it
has supplied – and users need to take precautions not to share sensitive information over
publicly available Wi-Fi.
In public spaces, Wi-Fi providers may want to consider additional measures to protect
children. More specifically, they can:





Proactively block access to web addresses known to contain content that is
inappropriate for a wide audience, in addition to their efforts to block access to child
sexual abuse material.
Include clauses in terms and conditions of use that forbid the use of Wi-Fi service to
access or display any material that may be unsuitable in an environment where
children are present. The terms and conditions should also include clear
mechanisms regarding the consequences of infringements of such rules.
Take all measures to protect against unauthorized access such as
manipulation/loss of personal data.
Install filters on the Wi-Fi system to reinforce and underpin the policy on
inappropriate material.
Provide procedures and software to assist in the control and monitoring of
children’s access to Internet content.
25
2.3 Content providers, online retailers and app developers
The Internet provides all types of content and activities, many of which are intended for
children. Content providers, online retailers and app developers have tremendous
opportunities to build safety and privacy into their offerings for children and young people.
Table 4 provides guidance for content providers, online retailers and applications
developers on policies and actions they can take to enhance child online protection and
participation.
Table 4. COP checklist for CONTENT PROVIDERS, ONLINE RETAILERS
AND APP DEVELOPERS
Integrating child
rights
considerations
into all
appropriate
corporate policies
and management
processes
Content providers, online retailers and apps developers can help identify,
prevent, and mitigate adverse impacts of ICTs on children’s rights, and
identify opportunities to support the advancement of children’s rights.
Refer to the general guidelines in table 1.
In collaboration with government, law enforcement, civil society and
hotline organizations, content providers, online retailers and apps
developers can play a key role in combating child sexual abuse material by
taking the following actions:
Be prepared to handle child sexual abuse material and report cases to the
appropriate authorities. If a relationship with law enforcement and a national
hotline is not already established, engage with them to develop processes
together.
Developing
standard
processes to
handle child
sexual abuse
material
Specify that the business will collaborate fully with law enforcement
investigations in the event that illegal content is reported or discovered, and
note details regarding such penalties as fines or cancellation of billing
privileges.
Have processes in place to immediately remove or block access to child
sexual abuse material – including notice and takedown processes to remove
illegal content as soon as it is identified.
Ensure that relevant third parties with whom the company has a contractual
relationship have similarly robust notice and takedown processes in place.
Work with internal functions such as customer care, fraud and security to
ensure that business can submit reports of suspected illegal content directly to
law enforcement and hotlines. Ideally, this should be done in a way that does
not expose front-line staff to the content and re-victimize the affected
child/children. To address situations where staff may be exposed to abusive
material, implement a policy or programme to support staff resiliency, safety,
and well-being.
Include data retention and preservation policies in order to support law
enforcement in the event of criminal investigations through such activities as
capturing evidence. Document the company’s practices for handling child
sexual abuse material, beginning with monitoring and extending to the final
transfer and destruction of the content. Include a list of all personnel
responsible for handling the material in the documentation.
26
Promote reporting mechanisms for child sexual abuse material and make sure
that customers know how to make a report if they discover such content. If a
national hotline is available, offer links to that hotline from the corporate
website and from any relevant content services promoted by the company.
If a company is operating in markets with less developed regulatory and law
enforcement oversight of this issue, it can refer reporters to the International
Association of Internet Hotlines at www.inhope.org/gns/home.aspx, where any
of the international hotlines can be selected to make a report.
Resources:
Vodafone, ‘Illegal Content’, www.vodafone.com/content/parents/getinvolved/illegal_content.html
GSMA Mobile Alliance Against Child Sexual Abuse Content, ‘Preventing
Mobile Payment Services from Being Misused to Monetise Child Sexual
Abuse Content’,
www.google.com/url?q=http://www.gsma.com/publicpolicy/wpcontent/uploads/2012/03/A4-16pp-Mobile-alliance-mpaymentsWEBversion.pdf&sa=U&ei=DtNFU4HNB6idyQGzmYCYBg&ved=0CAUQFjAA
&client=internal-uds-cse&usg=AFQjCNGoIRDAOvjDSzfpZYUoNBxRtIPYFw
Content providers, online retailers and app developers can help create a
safer, more enjoyable digital environment for children of diverse ages by
taking the following actions:
Work with others in the industry to develop content classification/age rating
systems that are based on accepted national or international standards and
consistent with approaches taken in equivalent media.
Where possible, content classifications should be consistent across different
media platforms, for example, a film trailer in a movie theatre and on a
smartphone would show customers the same classifications.
Creating a safer
and ageappropriate online
environment
To help parents and others decide whether content is age-appropriate for
children, build applications and services in all media to align with content
rating systems. Adopt appropriate age-verification methods to prevent children
from accessing age-sensitive content, sites, products or interactive services.
Provide advice and reminders about the nature and age-classification of the
content they are using.
A company that offers audiovisual and multimedia services might want to
provide a personal identification number (PIN) to users who seek to access
content that can be harmful for children.
Ensure transparency in terms of pricing for products and services, and
information collected about users. Ensure that data collection policies comply
with relevant laws concerning children’s privacy, including whether parental
consent is required before commercial enterprises can collect personal
information from or about a child.
Make sure that advertising or commercial communication is clearly
recognizable as such.
Supervise content made available online and adapt it to the user groups who
are likely to access it, for example, by establishing appropriate policies for
online advertising to children. If the content offering supports an interactive
element, such as commenting, online forums, social networks, gaming
platforms, chat rooms or message boards, communicate a clear set of ‘house
rules’ in customer-friendly language within the terms of service and user
guidelines.
27
Educating
children, parents
and teachers
about children’s
safety and their
responsible use of
ICTs
Content providers, online retailers and app developers can complement
technical measures with educational and empowerment activities by
taking the following actions:
Provide customers with specific and clear information about content, such as
the type of content, age ratings/restrictions, strong language or violence –
along with the corresponding parental controls that are available, how to report
misuse and inappropriate or illegal content, and how reports will be handled.
Encourage adults, including parents and teachers, to be involved in children’s
online content consumption, so that they can assist and guide children in the
choice of content when they are making a purchase, as well as help establish
rules of behaviour.
Provide rules of use in clear and accessible language that encourage children
to be vigilant and responsible when they are navigating the Internet.
Build age-appropriate tools such as tutorials and help centres. Work with
online/in-person prevention programmes and counselling clinics when
appropriate. For example, if there is a risk of children becoming obsessively
engaged with technology such as games, making it difficult for them to
develop personal relationships or take part in healthy physical activities, a site
could provide a contact link for a helpline or counselling service.
Content providers, online retailers and app developers can encourage and
empower children by supporting their right to participation through the
following actions:
Promoting digital
technology as a
mode to further
civic engagement
Develop and/or offer a range of high-quality content that is age-appropriate. In
addition to being attractive and usable, reliable and safe, such content can
contribute to children’s physical, mental and social development by providing
new opportunities to entertain and educate.
Provide information about a service to highlight the benefits the child would
obtain by behaving well and responsibly, such as using the service for
creative purposes.
2.4 User-generated content, interactive and social media service
providers
There was a time when the online world was dominated by adults, but it is now clear that
children and adolescents are major participants, on multiple platforms, in creating and
sharing in the explosion of user-generated content.
Table 5 which has been adapted from the rules applied by one of the largest social network
provides guidance for user-generated content, interactive and social media service
providers on policies and actions they can take to enhance child online protection and
participation.
Table 5. COP checklist for USER-GENERATED CONTENT, INTERACTIVE
AND SOCIAL MEDIA SERVICE PROVIDERS
Integrating child
rights
considerations into
all appropriate
User-generated content, interactive and social media service providers can
identify, prevent and mitigate the adverse impacts of ICTs on children’s
rights, and identify opportunities to support the advancement of children’s
rights.
28
corporate policies
and management
processes
Refer to the general guidelines in table 1.
In collaboration with government, law enforcement, civil society and hotline
organizations, user-generated content, interactive and social media service
providers can play a key role in combating child sexual abuse material by
taking the following actions:
All sites should have procedures in place to provide immediate assistance to
law enforcement during emergencies and for routine inquiries.
Specify that the business will collaborate fully with law enforcement
investigations in the event that illegal content is reported or discovered, and
note details regarding such penalties as fines or cancellation of billing
privileges.
Work with internal functions such as customer care, fraud and security to
ensure that the business can submit reports of suspected illegal content directly
to law enforcement and hotlines. Ideally, this should be done in a way that does
not expose front-line staff to the content and re-victimize the affected
child/children. To address situations where staff may be exposed to abusive
material, implement a policy or programme to support staff resiliency, safety
and well-being.
Use terms of service and conditions to prohibit illegal content and behaviour,
highlighting that:
- illegal content, including child sexual abuse material, will not be tolerated;
- the company will collaborate fully with law enforcement investigations in the
event that illegal content is reported or discovered.
Developing
standard processes
to handle child
sexual abuse
material
Document the company’s practices for handling child sexual abuse material,
beginning with monitoring and extending to the final transfer and destruction
of the content. Include a list of all personnel responsible for handling the
material in the documentation.
Adopt policies regarding ownership of user-generated content, including the
option to remove user-created content at the user’s request. Remove content
that violates the provider’s policies and alert the user who has posted it about
the violation.
Indicate that a user’s failure to comply with policies for acceptable use will have
consequences, including:
- removal of content, suspension or closure of their account;
- revoking a user's ability to share particular types of content or use certain
features;
- referring issues to law enforcement.
Promote reporting mechanisms for child sexual abuse material or any other
illegal content and make sure that customers know how to make a report if they
discover such content.
Build systems and provide trained staff to assess issues on a case-by-case
basis and take appropriate action. Establish comprehensive and well-resourced
user-support operation teams. Ideally, these teams would be trained to handle
different types of incidents in order to ensure that adequate response is
provided and appropriate actions are taken. When the user files a complaint,
depending on the type of incident, it will be routed to appropriate staff.
The company might also set up special teams to handle user appeals for
instances when reports may have been filed in error.
29
Have processes in place to immediately remove or block access to child sexual
abuse material – including notice and takedown processes to remove illegal
content as soon as it is identified. Ensure that third parties with whom the
company has a contractual relationship have similarly robust notice and
takedown processes in place.
Resource:
GSMA Mobile Alliance Against Child Sexual Abuse Content, ‘Notice and Take
Down Process’, www.gsma.com/publicpolicy/wpcontent/uploads/2012/07/Mobilecontributiontonoticeandtakedown.pdf
Develop technical systems that can detect known illegal content and can
prevent it from being uploaded, including to private groups, or flag it for
immediate review by the company’s safety team. Where possible, create
proactive technical measures to analyse the objects and metadata linked to a
profile to detect criminal behaviour or patterns, and take action appropriately.
If the application or service allows customers to upload and store photographs
on servers that are owned or operated by the company, have processes and
tools in place to identify images that are most likely to contain child sexual
abuse material. Consider proactive identification techniques such as scanning
technology or human review.
User-generated content, interactive and social media service providers can
help create a safer, more enjoyable digital environment for children of
diverse ages by taking the following actions:
Communicate in customer-friendly language within the terms of service and
user guidelines a clear set of ‘house rules’ that define:
- the nature of the service and what is expected of its users;
- what is and is not acceptable in terms of harmful content, behaviours,
language as well as prohibiting illegal usage;
- consequences of any breach, for example, reporting to law enforcement and
suspension of the user’s account.
Key safety and legal messages should be presented in an age-appropriate
format (i.e. utilizing intuitive icons and symbols) both at signup and in a
timely manner as different actions are taken on the site.
Creating a safer
and ageappropriate online
environment
Make it easy for customers to report concerns about misuse to customer care,
with standard and accessible processes in place to deal with different concerns
– for example, if a customer is receiving unwanted communications (spam,
bullying) or has seen inappropriate content.
Provide age-appropriate content sharing and visibility settings. For example,
make privacy and visibility settings for children more restrictive than the settings
for adults by default.
Enforce minimum age requirements, and support the research and
development of new age-verification systems such as biometrics, using known
international standards for the development of such tools. Take steps to identify
and remove underage users who have misrepresented their age to gain access.
If they are not already in place, set up appropriate sign-on processes to
determine whether users are old enough to access the content or service, and
community age-verification systems linked to a reporting function or a help
desk/centre that encourage users to report people who have falsified their age.
Protect younger users from uninvited communication, and ensure that privacy
and information-collection guidelines are in place.
Find ways to review hosted images and videos, and delete inappropriate ones
when found. Tools such as hash scanning of known images and image
30
recognition software are available to assist with this. Photos and videos can be
pre-checked to make sure that children do not publish sensitive personal
information about themselves or others.
A number of measures may be used to control access to user-generated
content and protect children online against inappropriate or illegal content.
Make sure that secure passwords are used as a step towards protecting
children in gaming and other social media settings. Other techniques include:
- giving parents the ability to control who contacts their children;
- reviewing discussion groups to find harmful subject matter, hate speech and
illegal behaviour, and deleting such content when it is found to violate the
terms of use;
- developing tools that actively seek to remove content that is illegal/in breach
of the company’s terms of condition and service, as well as tools to prevent
uploading of known illegal content to the site;
- pre-moderating message boards with a team of specialized children’s
moderators who screen for content that is in contradiction to the published
‘house rules’ – each message can be checked before it is published, and
moderators will also spot and flag suspicious users, as well as users in
distress;
- a team of community hosts who serve as the first point of contact for the
moderators when they have concerns about a user.
Be responsible for reviewing commercial content, including in forums, social
networks and gaming sites. Implement appropriate standards and rules to
protect children from age-inappropriate advertising, and establish clear limits
for online advertising to children.
User-generated content, interactive and social media service providers can
complement technical measures with educational and empowerment
activities by taking the following actions:
Create a section dedicated to safety tips, articles, features and dialogue about
digital citizenship, as well as links to useful content from third-party experts.
Safety advice should be easily spotted and provided in easy-to-understand
language. Platform providers are also encouraged to have a uniform navigation
interface across different devices, such as computers, tablets or mobile phones.
Educating children,
parents and
teachers about
children’s safety
and their
responsible use of
ICTs
Offer parents clear information about the types of content and services available
– including, for example, an explanation of social networking sites and locationbased services; how the Internet is accessed via mobile devices; and the
options available for parents to apply controls.
Inform parents about how to report abuse, misuse, and inappropriate or illegal
content, and how the report will be handled. Let them know what services are
age restricted, along with other ways to behave safely and responsibly when
using interactive services.
Establish a ‘trust and reputation’-based system to encourage good behaviour
and enable peers to teach best practices to each other by example. Promote
the importance of social reporting, which allows people to reach out to other
users or trusted friends to help resolve a conflict or open a conversation about
troubling content.
Provide advice and reminders about the nature of a given service or content
and how to enjoy it safely. Build guidelines into interactive services, for
example, with safety pop-ups that remind users of appropriate and safe
behaviour such as not giving out their contact details.
31
Promote digital
technology as a
mode to further
civic engagement
User-generated content, interactive and social media service providers can
encourage and empower children by supporting their right to participation.
Refer to the general guidelines in table 1.
2.5 National and public service broadcasting
Children and young people are a significant audience for content developed by
broadcasting services, which is increasingly accessible online. National and public service
broadcasters are working to offer the same level of security for online viewing that is
applied to television and radio.
Table 6 provides guidance for national and public service broadcasters on policies and
actions they can take to enhance child online protection and participation.
Table 6. COP checklist for NATIONAL AND PUBLIC SERVICE
BROADCASTING
Integrating
child rights
considerations
into all
appropriate
corporate
policies and
management
processes
Developing
standard
processes for
National and public service broadcasters can identify, prevent and mitigate the
adverse impacts of ICTs on children’s rights, and identify opportunities to
support the advancement of children’s rights by taking the following actions:
Develop policies that safeguard the welfare of children who contribute content
online, in accordance with licensing agreements to consider the physical/emotional
welfare and dignity of people under 18 who are involved in programmes
(irrespective of consent that might have been given by a parent or other adult).
Nominate a child protection policy manager or other designated person who can
be contacted in relation to child online protection issues. If a child is at risk of
harm, the child protection policy manager should immediately alert the appropriate
authorities.
In collaboration with government, law enforcement, civil society and hotline
organizations, national and public service broadcasters have a key role to play
in combating child sexual abuse material by taking the following actions:
32
handling child
sexual abuse
material
In cases of child sexual abuse material, staff should contact the executive
management team that is responsible for reporting it to the appropriate authorities.
In addition:
- alert national law enforcement agencies immediately;
- alert their manager and report the material to the child protection policy
manager;
- contact the internal investigation service by phone or email with details of the
incident and to ask for advice;
- wait for advice from the relevant agency before deleting the material, saving
it to a shared space or forwarding it.
If the material is uploaded on a non-broadcaster space, it should be reported
directly to an organization specialized in Internet safety that operates a hotline
reporting system for members of the public and information technology
professionals to report specific forms of potentially illegal online content.
Resources:
Child Exploitation and Online Protection Centre, CEOP Command, UK,
http://ceop.police.uk
-
Internet Watch Foundation, www.iwf.org.uk
Implement a swift and robust escalation strategy if, for example, child sexual
abuse material is posted or illegal conduct is suspected. Towards this end:
- offer users a simple, easily accessible method of alerting the broadcaster to
breaches of any rules of the online community;
- remove content that breaks the rules;
- take special care to mitigate risk around content, contact and conduct when
running interactive online spaces designed to appeal to children.
- Before uploading broadcaster material onto a social networking site, be
aware of the site’s terms and conditions. Be sensitive to minimum age
requirements on different social networking sites.
The terms and conditions of each online space should also include clear
mechanisms of reaction to infringements of such rules. Before uploading
broadcaster material onto a social networking site, be aware of the site’s terms
and conditions.
National and public service broadcasters can help create a safer, more
enjoyable digital environment for children of diverse ages by taking the
following actions:
Creating a
safer and ageappropriate
online
environment
Ensure that website moderators and hosts are prepared to remove content that
breaks the site’s ‘house rules’. Hosts can improve the user experience for children
by encouraging positive behaviour and defusing disputes before they get out of
hand.
Ensure pre-moderation of interactive spaces designed for children; active hosting
can encourage an atmosphere where bullying and harassment are not acceptable.
Unacceptable behaviour includes:
- posting nasty or threatening comments on someone’s profile;
- setting up fake profiles or hate sites to humiliate a victim;
- sending chain messages and attachments with harmful intent;
- hacking into someone's account to send offensive messages to others.
Take special precaution with staff members or collaborators that work with children
– including anyone moderating a public electronic interactive communication
service that is likely to be used wholly or mainly by children. These roles could
require a background check with police authorities.
33
Decide what level of engagement is desired before launching a website, online
profile or web page. Sites aimed to reach children should only present content that
is suitable for a young audience; if in doubt, the national authorities in charge of
child protection may be consulted.
Provide clear and factual content labelling. Be mindful that users can arrive at
inappropriate content by following links on third-party sites that bypass the
broadcaster home page or other contextualizing pages.
Refer any incident of suspected grooming promptly to the online or interactive
executive management team that is responsible for reporting it to the appropriate
authorities:
- make sure that a team member is available by phone when online interactive
services are aimed to a young audience – the number should also be
accessible via the broadcaster’s switchboard;
- establish common email addresses linked to the function (not the names) of
team members to automatically alert those on duty of incidents;
- when a content producer refers a report of suspected grooming to the
interactive executive management team, she or he should also report it to
the nominated child protection policy manager;
- make it possible for users of the broadcaster’s site to report suspected
grooming incidents directly to authorities.
Prioritize the safety and well-being of the child at all times. Always act within
professional boundaries and ensure all contact with children is essential to the
programme, event, activity or project. Never take sole responsibility for a child; if a
child needs care, alert the parent or chaperone. Listen to and respect children at
all times. If anyone is behaving inappropriately around children, report the concern
to the local child protection contact at the broadcaster.
National and public service broadcasters can complement technical measures
with educational and empowerment activities by taking the following actions:
Make safety information, including advice links, prominent, easily accessible and
clear when online content is likely to appeal to a high proportion of children.
Educating
children,
parents and
teachers about
children’s
safety and their
responsible
use of ICTs
Resource:
BBC, ‘Guidance: Interacting with Children and Young People Online’,
www.bbc.co.uk/editorialguidelines/page/guidance-children-interacting-summary
Offer a parental guidance tool, such as a ‘lock’ for control of content that can be
accessed through a particular browser.
Resource:
BBC, ‘Parental Guidance Lock’, www.bbc.co.uk/guidance; ‘CBeebies’,
www.bbc.co.uk/iplayer/cbeebies; and iPlayer, www.bbc.co.uk/iplayer/cbbc
Cooperate with parents to ensure that information disclosed on the Internet about
children does not put them at risk. How children are identified in broadcasters’
content requires careful consideration and will vary according to the context.
Obtain children’s informed consent when featuring them, and respect any refusal
to take part.
Promoting
digital
technology as
a mode to
further civic
engagement
National and public service broadcasters can encourage and empower
children by supporting their right to participation.
Provide children with challenging, educational, enjoyable and interesting content
that helps them make sense of the world in which they live.
Refer to the general guidelines in table 1.
34
2.6 Hardware manufacturers, operating system developers and app
stores
Children today are accessing the Internet through an array of electronic devices, from
laptops to tablets to cell phones and beyond. Hardware manufacturers can provide built-in
technical mechanisms along with educational and empowerment activities in order to
promote a safer online environment for children.
Table 7 provides guidance for hardware manufacturers, operating system developers and
app stores on policies and actions they can take to enhance child online protection and
participation.
Table 7. COP checklist for HARDWARE MANUFACTURERS, OPERATING
SYSTEM DEVELOPERS AND APP STORES
Integrating child
rights
considerations
into all
appropriate
corporate policies
and management
processes
Developing
standard
processes to
handle child
sexual abuse
material
Creating a safer
and ageappropriate online
environment
Hardware manufacturers, operating system developers and app stores can
identify, prevent and mitigate the adverse impacts of ICTs on children’s
rights, and identify opportunities to support the advancement of children’s
rights.
Refer to the general guidelines in table 1.
In collaboration with government, law enforcement, civil society and
hotline organizations, hardware manufacturers, operating system
developers and app stores can play a key role in combating child sexual
abuse content.
Refer to the general guidelines in table 1
Hardware manufacturers, operating system developers and app stores can
help create a safer, more enjoyable digital environment for children of
diverse ages by taking the following actions:
Use terms and conditions to draw users’ attention to content in the company’s
online services, such as app stores, that might not be appropriate for all ages,
whether originating from the manufacturer or from a third party. The terms and
conditions should also include clear mechanisms for reporting and dealing
with infringements of such rules.
Offer easy-to-use parental control options that allow parents to restrict the
services and content children can access when using electronic devices.
These restrictions can include Internet access, access to social media,
application/game purchase and installation, and use of location services.
Educating
children, parents
Hardware manufacturers, operating system developers and app stores can
complement technical measures with educational and empowerment
activities by taking the following actions:
35
and teachers
about children’s
safety and their
responsible use of
ICTs
Promoting digital
technology as a
mode to further
civic engagement
Support customers by making guidelines available for family online safety,
encouraging parents and caregivers to:
- become familiar with products and services children are using;
- ensure moderate use of electronic devices by children as part of a healthy
and balanced lifestyle;
- pay close attention to children’s behaviour in order to identify changes that
could indicate cyberbullying or harassment.
Hardware manufacturers, operating system developers and app stores can
encourage and empower children by supporting their right to participation.
Refer to the general guidelines in table 1.
36
37